CPCB Draft Guidelines 2026 for Category III Multilayered Plastic Packaging Waste Management

The Central Pollution Control Board (CPCB) has released draft guidelines for managing Category III multilayered plastic packaging waste, or MLP waste. Issued in September 2026, the document is currently open for public consultation, which means it is still a draft and should not be treated as a final or legally effective guideline yet.

The draft looks at what should happen to Category III packaging after it becomes waste. It covers collection, segregation, Material Recovery Facilities, transportation, recycling, aluminium and paper recovery, end-of-life treatment, quality testing and monitoring through the Extended Producer Responsibility framework. CPCB has also discussed how newer recycling technologies may be evaluated and how packaging design itself could become easier to recycle in the future. 

For Producers, Importers and Brand Owners, Plastic Waste Processors, packaging companies and recyclers, the document gives a clear indication of the direction CPCB is considering for difficult-to-process multilayer packaging.

CPCB Draft Guidelines at a Glance

The draft is meant to provide technical and operational guidance across the complete Category III waste-management chain rather than dealing only with final disposal. 

Why Has CPCB Proposed New Guidelines for Category III Multilayered Plastic Packaging Waste?

The story behind these guidelines begins with proceedings before the National Green Tribunal.

According to the CPCB document, an NGT order dated 12 November 2025 directed CPCB to explore whether common guidelines could be prepared for multilayered plastic packaging waste. A later order dated 9 February 2026 referred to the need to examine solutions for separating plastic and aluminium layers or finding suitable alternatives. CPCB filed a status report on 15 April 2026, and the matter was subsequently heard on 16 April 2026. 

There was already an older CPCB framework. In 2018, CPCB had issued guidelines dealing with disposal of the non-recyclable fraction of multilayered plastic waste.

A lot has changed since then.

The draft itself points to:

• amendments made to the Plastic Waste Management Rules, 
• introduction of EPR Guidelines for Plastic Packaging, 
• the Solid Waste Management Rules, 2026, 
• development of newer recycling technologies, 
• practical experience gained from implementation. 

CPCB therefore considers it necessary to update the approach to Category III waste so that recovery, recycling, traceability and final processing are looked at together. 

Regulatory Framework for Category III Multilayered Plastic Packaging Waste

The September 2026 draft does not operate in isolation. It sits alongside rules and EPR requirements that already govern plastic packaging.

Plastic Waste Management Rules, 2016

The Plastic Waste Management Rules, 2016 form the basic legal framework.

Among other things, the rules deal with segregation, handling and management of plastic waste and assign responsibilities to different entities involved in the waste chain. 

For EPR purposes, the draft refers to producers, importers, brand owners, Plastic Waste Processors, manufacturers and importers of plastic raw material and certain manufacturers of compostable or biodegradable plastic items. The source also records specific exclusions for micro and small enterprises in particular producer and brand-owner categories, so applicability should always be checked against the actual entity and activity. 

EPR Guidelines for Plastic Packaging

The EPR Guidelines for Plastic Packaging were published on 16 February 2022 under the PWM framework.

EPR links the quantity and category of plastic packaging placed on the market with corresponding obligations for collection, recycling or other permitted processing.

PIBOs can use mechanisms such as:

• collection points, 
• Material Recovery Facilities, 
• deposit-refund systems, 
• buy-back arrangements, 
• other collection networks. 

The waste eventually needs to reach an appropriate registered or authorised processing route. 

Solid Waste Management Rules, 2026

The draft also relies heavily on source segregation.

Under the Solid Waste Management framework referred to by CPCB, plastic waste forms part of the dry waste stream. Separate handling at the point of generation makes secondary segregation and recycling easier later. 

Earlier CPCB Guidelines

CPCB's 2018 guidance focused more heavily on managing non-recyclable MLP fractions.

The 2026 consultation draft takes the discussion further. Instead of looking only at disposal, it explores how different components of multilayer packaging can be recovered before the remaining fraction is sent to an authorised end-of-life route.

What Is Category III Multilayered Plastic Packaging?

This is one of the most important points for businesses.

For the draft, Category III MLP means multilayer packaging containing at least one plastic layer and at least one layer made from a material other than plastic.

The non-plastic layer may be made from material such as:

• aluminium foil, 
• paper, 
• paperboard, 
• another qualifying non-plastic barrier material. 

CPCB expressly states that multilayer packaging made entirely from different types of plastic belongs to Category II and is outside the scope of these Category III guidelines. 

In practice, the packaging structure matters more than how the pack looks from the outside.

Category II vs Category III Multilayered Plastic Packaging

The distinction can be especially important for companies selling food, pharmaceutical, beverage, cosmetics and FMCG products.

For example, CPCB says multilayer PE milk or oil pouches that do not contain a non-plastic layer remain Category II. By comparison, qualifying aseptic cartons containing paperboard, plastic and aluminium fall under Category III. 

Which Packaging Products May Fall Under Category III?

CPCB gives several examples of waste streams that may fall within Category III, subject to their actual material construction.

These include:

Foil-Based Food and Confectionery Packaging

Some biscuit wrappers and confectionery packs contain plastic together with aluminium foil.

Where the material structure meets the Category III definition, the packaging may be considered for:

material separation, 

delamination, 

aluminium recovery, 

authorised EOL treatment where recovery is not suitable. 

Foil-Based Sachets and Pouches

These may combine PET or another plastic with aluminium foil or another non-plastic layer.

Small sachets are difficult to collect because they are light and dispersed. Aggregation therefore becomes particularly important.

Aseptic Cartons

Paperboard-based cartons containing plastic and aluminium are treated as Category III.

The draft discusses hydropulping to recover paper fibre, followed by treatment or recovery of the remaining PolyAl fraction.

Laminated Tubes

Qualifying aluminium-barrier or other plastic/non-plastic laminated tubes may be sent for material recovery, aluminium recovery, composite product manufacture or authorised processing.

Pharmaceutical Strip Packs and Lidding Foils

Pharmaceutical packaging containing plastic together with aluminium foil is another stream specifically discussed by CPCB.

Post-Industrial Converter Waste

Trims, rejects and skeleton waste generated during packaging conversion can also fall under Category III where plastic is combined with non-plastic material.

Post-industrial waste may be easier to process because its composition is often known and it is normally cleaner than post-consumer packaging. 

Who Will Be Affected by the CPCB Draft Guidelines?

The proposed system spreads responsibility across the waste chain.

Producers, Importers and Brand Owners

PIBOs have a direct connection with EPR because they introduce plastic packaging into the market.

Their role can involve:

• correct packaging categorisation, 
• EPR reporting, 
• supporting collection, 
• working with registered processors, 
• maintaining waste movement records, 
• fulfilling applicable EPR obligations. 

The existing PWM and EPR framework already contains duties in this area. The consultation draft adds more technical detail around Category III collection and recovery. 

Plastic Waste Processors

PWPs are the facilities that actually recycle or process the collected plastic waste.

Their work can include:

• recycling, 
• material recovery, 
• EOL processing, 
• uploading processing data, 
• maintaining mass balance, 
• generating eligible EPR certificates under the applicable framework. 

Urban Local Bodies

ULBs are an important link between households, commercial generators and recycling facilities.

The draft discusses responsibilities connected with:

• source segregation, 
• dry waste collection, 
• MRF operation, 
• transportation, 
• record maintenance, 
• integration of waste pickers, 
• linkage with registered processors. 

SPCBs and PCCs

State Pollution Control Boards and Pollution Control Committees are concerned with registration, monitoring and environmental enforcement.

The draft discusses verification of:

• processor capacity, 
• processing records, 
• material inputs, 
• recovered outputs, 
• rejects, 
• residues, 
• mass balance, 
• EPR Portal data, 
• environmental safeguards. 

Waste Pickers and Aggregators

This group matters because individual MLP packs have little value and are scattered across large areas.

Aggregators, waste picker organisations, cooperatives and SHGs can bring together small quantities until there is enough material for economical transport to a processing facility. 

Stakeholder Responsibilities at a Glance

CPCB itself presents MLP management as a shared system where each stakeholder has a different function. 

What Do the CPCB Draft Guidelines Propose?

Rather than treating MLP waste as a single mixed material, the proposed approach begins by asking what can actually be recovered from it.

The main areas covered are:

• source segregation, 
• organised collection, 
• secondary sorting, 
• MRF-based aggregation, 
• channelisation to registered facilities, 
• polymer recovery, 
• paper recovery, 
• aluminium recovery, 
• mechanical recycling, 
• advanced recycling, 
• authorised EOL processing, 
• testing of recycled material, 
• digital EPR monitoring, 
• evaluation of new technology, 
• better packaging design. 

The practical message is simple: recyclable material should be recovered first, and only the fraction that cannot reasonably be recovered should move towards an authorised end-of-life route.

Current Category III MLP Processing Infrastructure in India

CPCB's draft gives specific processing data as of 25 June 2026.

According to the draft, this registered infrastructure shows that there is already substantial capacity for recycling and EOL processing of Category III waste in India. CPCB also links this infrastructure with its central EPR Portal for monitoring and traceability. 

These figures describe registered infrastructure. They should not be treated as estimates of market value, revenue or actual annual waste generation.

How Should Category III MLP Waste Be Collected and Channelised?

A recycling system cannot work properly if the material never reaches the recycler. CPCB therefore spends considerable space on collection. The basic flow is:

Waste generation → Source segregation → Collection → MRF/aggregation → Secondary sorting → Registered recycler or authorised EOL processor

Step 1: Source Segregation

MLP waste should first be separated as part of the dry recyclable waste stream.

Keeping food waste, wet waste and other contaminants away from MLP can improve the quality of the material reaching the recycler.

Step 2: Collection

Depending on the location, waste can move through:

• door-to-door collection, 
• Dry Waste Collection Centres, 
• Material Recovery Facilities, 
• buy-back centres, 
• deposit-refund systems, 
• reverse logistics, 
• collection drives, 
• SHGs, 
• waste pickers, 
• authorised collection agencies. 

The draft does not assume that one collection method will work everywhere. 

Step 3: Aggregation and Secondary Segregation

At a MRF or aggregation point, the material can be sorted further.

• The draft suggests broad segregation into:
• recyclable MLP, 
• paper-based MLP, 
• foil-based MLP, 
• contaminated/non-recyclable fractions. 

Step 4: Channelisation

The processing route should then depend on the material.

For instance:

• Recyclable MLP waste can be sent to a registered recycler.
• Paper-based aseptic packaging may go through hydropulping or another suitable recovery process.
• Foil-based laminates can be treated through delamination or aluminium recovery.
• Non-recyclable MLP waste should be sent to an authorised End-of-Life (EOL) facility. 

Collection Models for MLP Waste

Different areas will need different collection systems.

For smaller towns and rural locations, setting up a separate recycling facility in every local area may not be economically sensible. CPCB therefore discusses cluster systems where material from adjoining areas is collected, aggregated and transported together. 

Role of PIBOs in Collection and Channelisation

PIBOs can become more involved in the physical collection side of EPR.

The draft says they may support:

• collection points, 
• aggregation centres, 
• MRFs, 
• storage, 
• baling infrastructure, 
• transportation, 
• buy-back arrangements, 
• other incentive-linked collection methods. 

They may also work with:

• ULBs, 
• Gram Panchayats, 
• aggregators, 
• waste picker organisations, 
• SHGs, 
• NGOs, 
• authorised agencies. 

The draft separately refers to keeping records of collection, transport, weighment, transfer and receipt by the processing facility. 

Documents and Traceability Records for Category III MLP Waste

For EPR compliance, physical waste and paperwork need to tell the same story.

The proposed traceability framework covers the complete movement from waste generation to final processing.

The draft says relevant tax invoices and transport records should support actual movement of MLP waste and help verify quantities reported under EPR. 

This is particularly important where businesses purchase or use EPR certificates. Data that exists only on the portal, without supporting physical records, can create compliance risk.

Which Recycling Technology Is Suitable for Category III MLP Waste?

The answer depends on what the packaging contains.

A plastic-paper pack cannot automatically be treated in the same way as plastic-aluminium foil. Even two foil laminates may need different processes if their polymers and adhesives are different.

The draft says technology selection should consider:

• material composition, 
• waste quality, 
• level of contamination, 
• degree of segregation, 
• available proven recycling technology, 
• environmental performance, 
• recovery efficiency, 
• quality of the recovered product, 
• marketability, 
• economic viability. 

Where material recycling is technically workable, CPCB gives it priority over final disposal. 

Recycling Technology Comparison

Mechanical Recycling of MLP Waste

Mechanical recycling is the most established technology discussed in the draft for suitable waste.

The process does not chemically break the polymer into new molecules. Instead, it cleans, reduces, mixes and reprocesses the plastic into a usable form.

Stage 1: Collection and Baling

Loose flexible plastic is extremely light. The draft refers to a loose bulk density of around 20-40 kg/m³ and discusses hydraulic bales in the 50-500 kg range. Baling makes the material easier and cheaper to transport. 

Stage 2: Sorting

The incoming material is sorted to remove:

• paper, 
• textile, 
• metal, 
• PVC, 
• incompatible plastics, 
• other contaminants. 

Advanced plants may also use Near-Infrared sorting systems.

Stage 3: Shredding

Sorted MLP is cut into smaller flakes.

The draft refers to:

• roughly 20-50 mm flakes after shredding, 
• further size reduction below 10 mm where needed. 

Stage 4: Washing and Drying

Not every material needs washing. Clean industrial MLP may move directly towards densification after dust removal. Contaminated post-consumer packaging may need washing. Where washed, the draft refers to drying flakes to below 3% moisture before extrusion. 

Stage 5: Agglomeration

Thin flakes do not feed easily into an extruder. Agglomeration turns them into denser material that can be processed more consistently.

Stage 6: Extrusion and Pelletisation

The final stage can include:

• melt filtration, 
• removal of contaminants, 
• degassing, 
• additive dosing, 
• pellet formation. 

The output is recycled MLP granulate that may be used in suitable non-food-contact applications. 

Advanced Recycling Technologies for Category III MLP

Some packaging structures are too mixed or contaminated for straightforward mechanical recycling.

For those streams, CPCB discusses more specialised technologies.

Pyrolysis

Pyrolysis heats suitable plastic-rich waste without oxygen.

Possible outputs include:

• pyrolysis oil, 
• combustible gas, 
• char. 

Where aluminium foil is present, some of it can remain in the solid residue and may later be recovered.

Solvent-Based Dissolution

This process uses a suitable solvent to dissolve a polymer layer selectively.

The dissolved polymer is then recovered and purified, while other materials such as paper or aluminium may remain separated.

Depolymerisation

Certain polymers, particularly PET-based layers, may be chemically broken into smaller molecular components that can be used again as feedstock.

Gasification

Gasification partially oxidises waste at high temperature to produce synthesis gas.

The draft stresses that such technologies need appropriate environmental controls, residue management and documented mass balance. 

How Can Aluminium Be Recovered from Foil-Based MLP?

Foil packaging contains a valuable material that does not necessarily need to be lost during disposal.

The draft discusses several recovery routes.

Eddy Current Separation

Eddy Current Separation is a physical method used to separate conductive aluminium from non-conductive material.

There is one important condition: the aluminium should first be released from the plastic or paper laminate.

Pre-treatment may involve delamination, solvent dissolution, pyrolysis or hydropulping to free the aluminium from the other packaging layers.

For properly separated foil, CPCB’s draft indicates 80-95% recovery and 90-98% aluminium purity under optimised conditions. Actual results will depend on the material and operating conditions, so these figures are not guaranteed for every facility.

Electrostatic Separation

Another option discussed is electrostatic separation.

The broad process involves:

• crushing, 
• fine grinding, 
• particle screening, 
• aluminium liberation, 
• high-voltage separation based on electrical conductivity. 

The draft describes recovery of about 99% and product purity above 97% under optimised conditions for the technology discussed. 

Other Aluminium-Recovery Routes

The consultation document also refers to:

• chemical delamination, 
• solvent dissolution, 
• recovery from pyrolysis residue, 
• processing of PolyAl recovered from aseptic cartons. 

Hydro-Pulping of Aseptic Cartons

Aseptic cartons are different from ordinary plastic laminates because paperboard forms a major part of their structure.

Mechanical Hydro-Pulping

Water and mechanical action are used to separate paper fibre from the polyethene-aluminium layer.

The recovered paper fibre can go into products such as recycled paper and paperboard.

The residual PolyAl can be used for:

• composite boards, 
• roofing sheets, 
• moulded products, 
• further plastic/aluminium recovery. 

Enzymatic Hydro-Pulping

CPCB also discusses an enzyme-assisted version of the process.

Here, enzymes help weaken the adhesive and fibre interface so the layers can separate more easily.

Potential advantages discussed include:

• improved fibre recovery, 
• reduced chemical use, 
• lower water requirement, 
• lower energy requirement, 
• less fibre damage. 

The draft is careful not to present enzymatic recycling as fully mature. It says wider deployment should depend on demonstrated technical feasibility, environmental performance, economic viability and statutory compliance. 

Environmental Safeguards for MLP Recycling Facilities

A recycling technology is useful only if the recycling process itself does not create another pollution problem.

The draft therefore discusses safeguards for advanced facilities.

Depending on the process, these may include:

• pollution-control equipment,
• emission control,
• dust control,
• feed preparation,
• solvent recovery,
• wastewater treatment,
• proper residue management,
• batch-wise records,
• recovery records,
• mass-balance documentation.

Advanced recycling facilities are also expected to operate with the statutory environmental approvals applicable to their activities. 

What Products Can Be Made from Recycled MLP?

Recycled MLP does not have only one end use.

CPCB identifies two broad routes.

Granulate-Based Conversion

In this method, MLP waste is first processed into pellets or granules, which can then be used in regular plastic-processing machines.

It may be used to make products such as pallets, crates, benches, dustbins, pipes, cable ducts, plastic lumber, sheets and other moulded items.

Direct Conversion

Some MLP waste can also be used directly after shredding or agglomeration, without first turning it into granules. It may then be converted into products such as boards, sheets, panels or other suitable recycled items. 

The draft mainly refers to non-food-contact applications, so the presence of recycled MLP should not automatically be treated as approval for food-contact packaging. 

What Happens to MLP That Cannot Be Recycled?

Some material will remain unsuitable for useful material recovery even after sorting and processing.

The draft sets out a practical hierarchy.

First Preference: Material Recycling

Recover plastic, paper, aluminium or another usable material wherever technically possible.

Second Preference: Direct Conversion

When granulates cannot be produced, some fractions can be used for direct conversion to product forms like boards and road material.

Remaining Fraction: Authorised EOL Route

Possible controlled routes include:

• cement kiln co-processing, 
• waste-to-energy, 
• pyrolysis, 
• other authorised applications. 

The draft makes it clear that open burning and improper landfill disposal are not acceptable routes for MLP waste. 

Quality Control and Testing of Recycled MLP

Producing recycled material is only half the job. The buyer also needs to know whether different batches are reasonably consistent.

CPCB therefore provides an indicative testing regime.

These figures appear in a public consultation draft. They should not be presented as final mandatory standards unless they are retained or otherwise made operative.

For direct-conversion products such as boards or sheets, CPCB says quality assessment may need to shift from granulate properties to the performance of the finished product. 

How Will EPR Compliance for Category III MLP Be Monitored?

The central CPCB EPR Portal connects regulatory data with actual plastic processing.

The portal covers functions such as:

• registration, 
• packaging data submission, 
• EPR obligation calculation, 
• processor reporting, 
• EPR certificate generation, 
• compliance monitoring. 

PIBOs placing Category III packaging on the market should report it under the correct category. CPCB specifically says Category II all-plastic multilayer packaging should not be treated as Category III. 

PWPs upload processed quantities.

Eligible EPR certificates are then linked with verified processing.

The draft also discusses automatic cross-checking between quantities reported by PIBOs and PWPs. Where figures differ, the lower quantity is taken for compliance purposes. Annual returns, inspections and audits provide an additional check. 

For businesses using Plastic Waste EPR Registration and ongoing EPR compliance systems, this means data accuracy is not enough on its own. Supporting physical records also matters.

Environmental Compensation and Compliance Risk

The draft mentions Environmental Compensation where applicable EPR obligations are not met. However, it does not introduce any new fixed penalty amount in this section.

Businesses should therefore pay more attention to the compliance gaps that can create problems, such as:

• reporting waste under the wrong category,
• incorrect quantity details,
• using an unregistered processor,
• missing weighment, invoice or transport records,
• differences between input and output data,
• weak residue records,
• unsupported processing claims, and
• unauthorised dumping or burning.

A proper EPR record should clearly show how the waste moved from collection to its final authorised processing facility.

How does CPCB evaluate New MLP Recycling Technologies?

CPCB does not treat every new recycling machine or process as automatically acceptable.

The draft refers to its Protocol for Evaluation of Technology for Waste Management, developed in June 2021.

It also refers to an MoEF&CC Office Memorandum dated 9 July 2026 connected with directions of the NGT.

For proposals involving dissolution techniques, the draft says evaluation should take place under CPCB's technology-evaluation protocol. Where feasible, a Standing Committee chaired by the Member Secretary, CPCB, is involved in the approval route described in the document. 

This distinction matters for technology companies.

A process being technically promising is not the same thing as it being automatically accepted as a regulatory processing route.

What Alternatives to Conventional MLP Does CPCB Discuss?

The consultation paper also asks a bigger question: can some difficult multilayer structures be redesigned before they become waste?

CPCB discusses several alternatives.

1. Mono-Material Packaging

Pouches made mainly from a single polymer family, such as PE or PP, can be easier to recycle than complex multi-material structures.

2. Compostable Bio-Based Films

The draft refers to materials such as PLA, PHA and cellulose films for suitable applications.

These materials still need the right collection and processing infrastructure.

3. Paper-Based Barrier Packs

Paper with suitable barrier coatings may provide an alternative for some products.

Its recyclability or compostability will depend on the coating used and the actual structure.

4. Recycled-Content Plastics

Post-consumer recycled plastics might help to minimize reliance on virgin plastic if they are deemed appropriate for certain applications.

5. Biodegradable Coatings

Starch-based coatings and biopolymers are mentioned as potential substitutes for coatings in some cases.

These options are presented for evaluation rather than as a compulsory replacement schedule. 

Packaging Redesign and the Future of MLP in India

The final part of the draft looks beyond waste plants and focuses on the packaging itself.

CPCB discusses reducing material complexity and looking at developments such as:

• aluminium-free aseptic cartons, 
• renewable-feedstock-based polymers, 
• high-barrier coatings, 
• improved recyclability, 
• design-for-circularity. 

The draft refers to products used in European markets but does not say they should be copied in India.

Before wider adoption, businesses would need to consider:

• product safety, 
• shelf life, 
• Indian climatic conditions, 
• existing recycling infrastructure, 
• raw material availability, 
• cost, 
• Indian standards and regulations. 

PIBOs may also consider pilot projects or technical studies before changing large packaging portfolios. 

How Could These Draft Guidelines Affect Businesses?

The likely effect will differ from one industry to another.

FMCG and Food Brands

These companies may need better information from packaging suppliers about the exact laminate structure. A pack described only as “flexible plastic” may not provide enough information to decide whether it belongs in Category II or Category III.

Pharmaceutical Companies

Foil-containing strip packs and lidding material deserve particular attention because the draft specifically discusses aluminium recovery from these streams.

Importers

Importers may need to check the packaging that comes with imported products, not just the imported product itself. Correct EPR categorisation remains important.

Recyclers

Recyclers may face closer expectations around:

• feedstock suitability, 
• input-output balance, 
• residue management, 
• pollution controls, 
• testing, 
• product quality. 

Challenges and Cost Implications

The draft does not give a standard implementation cost. That makes sense because the cost for a national FMCG brand will be completely different from the cost for a small recycler.

Collection Cost

MLP is light and spread across large areas. Even when a large volume exists, transporting loose packaging may not be economical.

Sorting Cost

Material has to be separated by:

• contamination, 
• polymer family, 
• paper content, 
• aluminium content, 
• recoverability. 

Processing Cost

Recyclers may need:

• balers, 
• shredders, 
• washers, 
• dryers, 
• extrusion equipment, 
• delamination systems, 
• aluminium recovery systems, 
• pollution-control systems. 

Testing Cost

Where recycled granulate is sold as a consistent industrial material, routine quality testing adds another operating requirement.

Documentation Cost

Traceability also takes people and systems. Invoices, weighment slips, transport documents, batch records and portal data need to match. The draft itself recognises that collection and channelisation remain a major constraint for MLP because the waste is low in weight and dispersed. 

Business Opportunities Created by Better MLP Waste Management

The same framework that creates compliance work can also create demand for new services and infrastructure. Possible areas include:

Registered Recycling

Better collection can provide processors with more consistent MLP feedstock.

Waste Aggregation

Aggregation businesses may become more valuable where individual quantities are too small to transport economically.

Material Recovery Facilities

MRFs can perform secondary segregation and prepare material before it reaches specialised processors.

Aluminium Recovery

Foil-based waste may create additional demand for:

• delamination, 
• eddy current separation, 
• electrostatic separation, 
• secondary aluminium recycling. 

Recycled Products

Recovered material can support manufacturing of:

• boards, 
• sheets, 
• panels, 
• pallets, 
• plastic lumber, 
• certain construction products. 

Technology Providers

The proposed framework may also create more opportunities for companies supplying recycling and waste-processing technology. This could include equipment for sorting, baling, shredding, hydropulping, aluminium recovery, chemical recycling and pollution control.

CPCB also notes that recycling clusters could offer shared infrastructure for smaller recyclers and newer technology providers, subject to the required environmental and statutory approvals.

Is the CPCB MLP Framework a Right Decision or an Additional Burden?

There is a fair argument on both sides. 

The strongest part of the proposal is its focus on material recovery before disposal. Plastic, aluminium and paper can all have value. Throwing them away together loses that value. The difficult part is collection.

A lightweight sachet may technically be recyclable, but recycling becomes meaningless if it costs too much to collect and transport.

The success of the final framework will therefore depend on whether the collection model is workable at ground level, especially outside major cities.

What Should PIBOs, Recyclers and Businesses Do Now?

The September 2026 guidelines are still at the public-consultation stage. Businesses should therefore avoid treating every recommendation as a new legal duty.

A practical approach is to divide work into two buckets.

A. Continue Existing Compliance

Organizations should look at compliance duties that they must fulfill under the existing PWM and EPR regime.

These may include, depending on the entity:

• EPR registration, 
• correct packaging categorisation, 
• accurate reporting, 
• annual returns, 
• use of registered processors, 
• valid environmental approvals, 
• required record-keeping. 

Companies needing support with EPR Registration Services should deal with their existing applicable requirements rather than waiting for the consultation process to finish.

B. Prepare for the Proposed Direction

At the same time, companies can begin reviewing:

1. Which packs are actually Category III?

Obtain laminate structures from packaging suppliers. 

2. Where does the waste go today?

Map collectors, aggregators and processors. 

3. Can the processor handle that particular laminate?

Registration alone does not answer every technology question. 

4. Is the paperwork complete?

Check invoices, weighment records and transport evidence. 

5. Can difficult packaging be redesigned?

Packaging and procurement teams can start evaluating easier-to-recycle alternatives. 

6. Is the final CPCB guidance being monitored?

A draft can change before publication. 

What Could Change After Public Consultation?

The September document should be read as CPCB's current proposal.

After consultation, CPCB could:

• retain the existing draft, 
• modify technical values, 
• change recommended processes, 
• clarify stakeholder duties, 
• revise technology sections, 
• change implementation language, 
• add further operational guidance. 

Businesses should therefore track the final CPCB publication and any subsequent instructions rather than using the consultation draft as if it were already a final notification.

The document itself also speaks about periodic review, capacity building and continued adoption of emerging technologies. 

How Corpseed Can Help with EPR Registration and Plastic Waste Compliance

Managing plastic packaging compliance is rarely limited to one registration. Businesses often need to connect packaging classification, EPR data, processing records, recycler details and environmental approvals.

Corpseed can support businesses across these areas through EPR Registration Services, EPR Compliance Services and Environmental Compliance Services, depending on the nature of the entity and its actual regulatory obligations.

1. EPR Applicability Assessment

Before filing anything, the first question should be whether EPR applies and in what capacity.

Corpseed can support businesses in reviewing:

• business activity, 
• producer/importer/brand-owner status, 
• plastic packaging used, 
• packaging categories, 
• applicable registration requirements. 

This helps avoid filing under an incorrect category.

2. EPR Registration Services

Businesses that fall within the applicable framework can use Corpseed's EPR Registration Services for support with:

• application preparation, 
• information review, 
• documentation organisation, 
• filing assistance, 
• clarification support during the process. 

No approval should be assumed until it is granted by the competent authority.

3. Plastic Packaging Category Review

The problem of improper classification of plastics is common.

Corpseed can help businesses assess whether available packaging data suggests:

• Category I, 
• Category II, 
• Category III, 
• Category IV, 
• Category V, 

subject to the actual legal definition and technical composition.

For complicated laminates, technical material information from the packaging manufacturer may still be required.

4. Plastic Waste EPR Registration Support

Importers, producers and brand owners that require Plastic Waste EPR Registration may need help organising entity and packaging data before filing.

Support can include:

• packaging-data review, 
• application information, 
• supporting documents, 
• portal filing assistance. 

5. EPR Compliance and Annual Return Support

Registration is only the starting point.

Ongoing compliance may include:

• packaging quantity records, 
• category-wise data, 
• recycling/EOL records, 
• certificate records, 
• annual return data, 
• internal compliance tracking. 

Corpseed's EPR Compliance Services can assist businesses with organising and reviewing these records.

6. Plastic Waste Processor Compliance Support

Recyclers and processors may have to meet a different range of compliance standards.

This includes:

• registration paperwork,
• environmental approval checks,
• capacity data,
• processing logs,
• traceability, and
• gap analysis. 

7. Recycler and PWP Documentation Review

PIBOs should not rely only on the EPR certificate. The supporting records behind the transaction are equally important as the EPR.

Corpseed can help review documents such as:

• processor registration details,
• invoices,
• weighment slips,
• waste-transfer records,
• processing proof, and
• traceability documents.

8. Environmental Compliance Services

Recycling and processing units may need different environmental approvals depending on their activity, process and location.

Corpseed can assist in identifying the applicable requirements and provide support for relevant environmental consents, authorisations and compliance documentation.

9. Regulatory Monitoring

Plastic waste compliance can change through CPCB directions, rule amendments, EPR Portal updates and new guidance.

Corpseed can help businesses keep track of these changes so they can review their compliance requirements and take timely action where needed.

Businesses can use ongoing compliance support to track:

• CPCB updates, 
• MoEF&CC changes, 
• EPR Portal developments, 
• SPCB/PCC instructions, 
• finalisation of the Category III MLP guidelines. 

For businesses looking for a CPCB EPR Registration Consultant, the better approach is to start with applicability and packaging classification before moving to registration and ongoing compliance.

Key Takeaways

The CPCB September 2026 document gives businesses a much clearer picture of how Category III MLP waste could be collected, processed and monitored in the coming years.

The main points are:

• The CPCB document is still open for public consultation, so businesses should not treat it as a final compliance requirement yet.
• Category III covers multilayer packaging that combines plastic with at least one non-plastic material.
• Packaging made only from different plastic layers continues to fall under Category II.
• One of the biggest practical issues is collecting and bringing scattered MLP waste together in workable quantities.
• Recycling should be the first option wherever the material can be recovered properly.
• Different materials such as plastic, paper and aluminium may need different recycling or recovery methods.
• The draft looks at both mechanical recycling and newer recycling technologies for difficult MLP waste.
• Proper testing, processing records and mass-balance details are becoming more important for traceability.
• The CPCB EPR Portal remains an important part of reporting, processing data and EPR certificate compliance.
• Existing EPR responsibilities continue to apply even while these draft guidelines are under consultation.
• Businesses should keep track of the final CPCB publication before treating any proposal in the draft as a compulsory requirement.